Canadian Regulatory Compliance for Stationary Battery Systems

Canadian Regulatory Compliance for
Stationary Battery Systems
North American Update
ComplianceKnowledgeCenter.com
What is Compliance?
In general:
compliance means conforming to a rule, such as:
 a specification, policy, standard or law.
For End Users:
Regulatory compliance describes the goal that corporations aspire to achieve
to ensure that personnel are aware of and take steps to comply with relevant
laws, codes and regulations.
Areas of Code Compliance for
Standby Power Battery Rooms
Safety Regulations:
Eye Wash & Personal
Safety Equipment
Fire Code :
Battery Electrolyte
Spill Containment &
Neutralization
Building Code:
Seismic Battery
Racking Requirements
Dangers in a Battery Room
Regulated Materials
• Sulfuric Acid
• Lead
0
3
Hazards
•
•
•
•
Chemical (Toxic & Corrosive)
Electrical
Explosive Gas
Seismic
2
W
Is Compliance Making You Crazy?
Areas of Battery Room Compliance
HazMat Spill
Cleanup Kit
Personal Safety
Equipment
Ventilation
Eyewash or
Shower
Hydrogen Gas
Monitor
Terminal
Insulation &
Barriers
Signage
Aisle Mats
Spill Containment &
Neutralization
Battery Rack Seismic
Certification
What are Standards?
 A published specification that establishes a common language
 Contains technical information or other precise criteria to follow
 Designed to be used as:
 A Guideline, Rule, or Definition
 “Best Practice”
 Can be Adopted as an Enforceable Code
 Institutes that Create Standards
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CSA – Canadian Standards Association
Ulc – Underwriters Laboratories of Canada
IEEE – Institute of Electrical Electronics Engineers
NFPA – National Fire Protection Association
Standards Organizations
 CSA (Canadian Standards Association)
 Electrical Safety: Z462-08 Section 6.3 Battery and Battery Rooms (Electrical Safety, PPE)
 ICC (International Code Council)
 International Fire Code 608 (Spill Containment, Signage, Thermal Runaway, Spill
Kits, Gas Monitoring)
 NFPA (National Fire Prevention Association)
 NFPA 1 Article 52 (Spill Containment, Signage, Thermal Runaway, Spill Kits, Gas Monitoring)
 NFPA 70E Electrical Safety in the Workplace, Article 320 (Training, Terminal Covers,
Ventilation, Spill Control, PPE)
 IEEE (Institute of Electrical and Electronic Engineers)
 IEEE 1578 Recommended Practice for Stationary Battery Electrolyte Spill Containment
and Management (Spill Containment)
 IEEE 484 Recommended Practice for Installation Design and Installation of Vented
Lead-Acid Batteries for Stationary Applications (PPE, Spill Containment, Ventilation)
 IEEE 1187 Recommended Practice for Installation Design and Installation of ValveRegulated Lead-Acid Batteries for Stationary Applications (PPE, Spill Containment,
Ventilation)
 IEEE 1657 Recommended Practice for Personnel Qualifications for Installation and
Maintenance of Stationary Batteries (Training, PPE)
What are Codes?
 Codes are Laws which are Adopted by All levels of Government
 Sources of Codes:
 Canadian Centre for Occupational Health and Safety
 ICC – International Code Council
– International Building Code (IBC)
» California Building Code (CBC)
– International Fire Code (IFC)
 NFPA – National Fire Protection Association
– National Electrical Code (NEC, NFPA 70)
– Uniform Fire Code (NFPA 1)
 Enforceable by Law – Mandatory Requirement
 Authority Having Jurisdiction
– Building Inspector
– Fire Inspector
– OSHA Inspector
Codes Considered in Designing
Standby Power Systems
 Model Codes
 International Building Code
 2012 current version, previous 2009 & 2006 versions
 NEW Battery Rack Seismic Testing Requirements
 tri-axial shake table tested and certified
 National Electrical Code
 NFPA 70
 Uniform Fire Code
 NFPA Chapter 52
 Still recognized in certain areas
 International Fire Code
 2012 Section 608, current version
Canadian Regulations
 Ministry of the Environment
 Clean Water Act
 Environmental Protection Act
 NFC (The National Fire Code of Canada)
 OH5 Hazardous Substances Containment
 Canadian Transportation of Dangerous Goods (TDG) Regulations
 49 CFR Hazardous Materials Regulations (Transportation, Training, Spill
Containment, Signage)
 Canada Occupational Health And Safety Regulations
 SOR/86-304 — Warning of Hazardous Substances 10.13 (Signage, Eyewash,
Training)
 Occupational Health and Safety Act
 Ontario Regulation 67/93 - Health Care And Residential Facilities (Signage & PPE)
 Ontario Health and Safety Reg 851 – (Shower/Eyewash)
 R.S.O. 1990, Chapter O.1 – (MSDS - Material Safety Data Sheets)
 Fire Protection and Prevention Act, 1997
 Ontario Regulation 213/07 - Fire Code – (Spill Containment)
2012 International Fire Code (IFC) Section 608
Stationary Storage Battery Systems
608.1 Scope
“Stationary storage battery systems having an
electrolyte capacity of more than 50 gallons (189 L)
for flooded lead-acid, nickel cadmium (Ni-Cd) and
valve-regulated lead-acid (VRLA)”
Verify with AHJ
Authorities Having Jurisdiction (AHJ)?
 Ministry of the Environment
 Fire Department code
enforcement
 CanOHS Inspector
 HazMat Inspector
 Insurance Carrier inspectors
 Loss Prevention
 Facility Owners and Managers
 Real Estate Professionals
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
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Environmental Compliance Manager
Corporate Health and Safety
Site Security and Human Resources
Environmental Health and Safety
Outside Environmental or Safety
Auditor
 Water Quality Inspectors
 Fish and Game
 Site Safety Manager
Any AHJ can require Spill Containment.
Copyright © 2011 EnviroGuard.
All Rights Reserved.
What is Considered a Battery Spill?
 “Unintentional release of hazardous material.”
 Common causes:
 Installation and Removal
 Handling (drops or punctures)
 Improper installation or support
 Operational





Over-charging / charger failure
Thermal runaway
Battery Explosion (hydrogen)
Jar crack due to plate growth
Seismic events
 Maintenance
 Water additions (electrolyte overflow)
 Jar Crack (punctures or unapproved cleaning fluids)
Source: IEEE
“Most spills occur during installation & maintenance.” - IEEE
The Problem? Damage to Rack & Floor
Substrate
The Problem? – Damage to Environment
Purpose & Terminology for Spill Containment
Spill Control (IFC 608)
Method and materials for the
control of a spill of electrolyte.
Neutralization (IFC 608)
Method and materials for the
neutralization of a release of
electrolyte.
Pillows
Pillows filled with chemicals to
neutralize and absorb spilled
electrolyte.
Barriers
Liner
Full spill control will typically
require 4” high barriers.
Acid resistant liner to contain
and control electrolyte spills.
Type of Neutralization Systems
Reactive Neutralization
Manually Applied
(MUST be Trained to Use)
Passive Neutralization
ALWAYS Ready
(Neutralizes upon Contact)
Importance of ULc for Spill Containment
 Tested by globally recognized
lab
 “a tested & proven means of
containment”
 Reduces Risk / Liability
 Streamlines Fire Permit
Sign-off and Future Inspection
Room or Rack Spill Containment?
Room Containment
Rack Containment
Type of Neutralization Systems
Passive Neutralization
ALWAYS Ready
(Neutralizes upon Contact)
Reactive Neutralization
Manually Applied
(MUST be Trained to Use)
Due Diligence Checklist – Site Assessment
Yes
No
Questions
Do you know and understand your safety and health responsibilities?
Do you have definite procedures in place to identify and control hazards?
Have you integrated safety into all aspects of your work?
Do you set objectives for safety and health just as you do for quality, production, and sales?
Have you committed appropriate resources to safety and health?
Have you explained safety and health responsibilities to all employees and made sure that
they understand it?
Have employees been trained to work safely and use proper protective equipment?
Is there a hazard reporting procedure in place that encourages employees to report all unsafe
conditions and unsafe practices to their supervisors?
Are managers, supervisors, and workers held accountable for safety and health just as they
are held accountable for quality?
Is safety a factor when acquiring new equipment or changing a process?
Do you keep records of your program activities and improvements?
Do you keep records of the training each employee has received?
Do your records show that you take disciplinary action when an employee violates safety
procedures?
Do you review your OSH program at least once a year and make improvements as needed?
Required Battery Room Safety Equipment
Requirement
Regulatory
Spill Control
IFC, Ontario Reg 213/07
Neutralization
IFC, Ontario Reg 213/07
Spill Clean-up Kit
IFC, Ontario Reg 213/07
Eyewash Station
Ontario Reg 851
Battery Room Signs
IFC, SOR/86-304, 67/93
Hydrogen Gas Monitoring
IFC
Thermal Runaway Protection
IFC
Battery Terminal Covers
NFPA 70E,
Acid-resistant Aisle Mats
TBD
Smoke Detectors
IFC, NFC
Fire Extinguishers
NFC
Personal Protection Equipment (PPE)
NFPA 70E, Ontario Reg
67/93
References
 BCI (Battery Council International)
http://www.batterycouncil.org
 Environment Canada
http://www.ec.gc.ca
 Transport Canada
http://www.tc.gc.ca
 Province of British Columbia
 Environment Management Act, Reg 449/2004, Recycling Regulation
http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/449_2004
 Product Stewardship for Lead-Acid Batteries:
http://www.env.gov.bc.ca/epd/recycling/batt/index.htm
 Ontario Ministry of the Environment
http://www.ene.gov.on.ca/environment
 Canadian Battery Association
http://canadianbatteryassociation.ca/
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Thank You
Bill Ryan
Email: BRyan@EnviroGuard.com
Call: 800-206-9884
ComplianceKnowledgeCenter.com
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Richard, 2011-05-27